National Writers Union – OSHA Testimony

OSHA Testimony – Colby

March 31, 2000

TESTIMONY OF GERARD COLBY, former National Vice President of the National Writers Union and currently Chair of the Political Issues Committee of the National Delegates Assembly of the National Writers Union, Co-Chair of the National Writers Union’s Book Division, and Chair of the Vermont Local of the National Writers.

OSHA Docket Office, Docket No. S-777

U.S. Department of Labor

200 Constitution Avenue, NW, Room N-2625

Washington, DC 20210

FAX: 202-693-1648

To Whom It May Concern

On behalf of the National Writers Union (NWU), UAW Local 1981, and as a former National Vice President and current Chair of the Political Issues Committee of its national Delegates Assembly, Co-Chair of the National Writers Union’s Book Division, and Chair of its Vermont Local, I hereby submit written testimony in support of the promulgation of an OSHA ergonomics standard.

While we find it beyond comprehension that, despite medical studies evidencing the need for such protection, workers who use computers are not initially covered by OSHA’s proposed standard, the 5,700 members of the National Writers Union strongly supports this proposed standard as an important step forward in public health and workplace safety. We believe that a law protecting workers from cumulative trauma disorders (hereinafter “CTD’s”) has long been overdue. Numerous members of our union have suffered debilitating injuries due to risk factors such as repetitive stress, required awkward postures, and unsafe design of workplaces, all of which are scientifically documented as risk factors for CTDs and more importantly, are scientifically documented as being a result of work-related factors. Some of our members have been maimed by such ergonomic risk factors. Some have had to resort to using voice activated software in order to maintain their livelihood as writers. These additional occupational expenses and the risk factors that caused them could have been avoided if an OSHA Ergonomics Standard had been promulgated.

CTDs and work-related factors are so serious that our members have engaged in the following activities to draw attention to them and raise public awareness:

* We have participated in OSHA Stakeholder meetings;

* We have attended health and safety trainings on ergonomics given by UAW Health and Safety Staff;

* We have published articles on ergonomics issues of health and safety;

* We have conducted ergonomic workshops at the 1999 NWU Delegates Assembly and at other events throughout the United States;

* We have strongly urged our Representatives in Congress to vote against any bills that would prevent an OSHA Ergonomics Standard from becoming law.

* And we have submitted written comments to OSHA on March 2, 2000 on the proposed ergonomics standard.

We are aware that practical ergonomics programs are already working in hundreds of worksites and that the Bureau of Labor Statistics 1998 Report showed the effectiveness of UAW-negotiated ergonomics programs, and that methods for measuring and relieving ergonomics streeses and procedures for carrying out practical ergonomics programs have already been developed and verified over the last decade. So, if the science is known, and it is, what valid reason can there be to delay action on an ergonomic standard or to wait completion of still an additional review by the National Academy of Sciences? For our members, who will be affected positively by an OSHA ergonomics standard and by the identifying of causes for injury, there is no valid reason for further delay. Without it, workers face not only injury, but denial of fair compensation from disability programs. There is no valid reason why they should have to risk further injury or be denied access to fair compensation for disabilities resulting from these injuries.

The 5700 writers throughout the United States in the National Writers Union, UAW Local 1981, who face the dangers of unsafe work every day with little or no recourse once they are injured, urge that our concerns over the need for an OSHA Egonomic Standard be considered with the seriousness that they deserve. In our democracy, the public relies on government to place the health and safety of the working citizens of this country over any special interests. We trust that the government is listening to its citizens, just as the citizens are watching to see if the government is responding with compassion.

The National Writers Union therefore strongly supports the recommendations of the Health and Safety Department of the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America and hereby resubmits those recommendations that were presented in March of this year in the pre-hearing comments of Jonathan Tasini,